The chief executive of Credit Suisse recently appeared in front of a Senate subcommittee to answer questions related to the bank’s role in aiding tax evasion. A similar hearing in 2008 resulted in a $780 million fine for Swiss bank UBS after the bank admitted helping U.S. taxpayers shield assets to avoid taxes. In conjunction […]

A QTIP trust, despite its silly name, is a valuable estate planning tool. QTIP, or “Qualified Terminable Interest Property” is a name derived from the tax law that legalises the tax benefits of the trust. When property is given to a spouse outright (not subject to a trust), it qualifies for what is known as […]

Eli S. Noff, Esq.,CPA, PartnerBrent Conrad In an effort to reduce persistent high unemployment rates resulting from the 2008 financial crisis, President Obama signed The Hiring Incentives to Restore Employment Act of 2010 (HIRE Act)1to incentivize employers to hire and retain workers. Tax incentives provided in the HIRE Act included: (1) a payroll tax holiday, […]

Eli S. Noff, Esq., CPA, Partner Under Internal Revenue Code (IRC) §6013(d)(3), spouses who file joint income tax returns are subject to joint and several liability for the income tax reported on those returns. In other words, the IRS will hold each spouse responsible for the entire amount of tax due. Sometimes, however, one spouse […]

On May 10, 2018, the United States Attorney for the District of Maryland announced that new Baltimore Police Commissioner Daryl De Sousa has been charged with three misdemeanor counts of willful failure to file a U.S. individual income tax return. Specifically, the charges allege that Commissioner De Sousa failed to file returns for tax years […]

On May 15, 2018, Maryland enacted laws which are projected to counteract the recent federal tax reform’s negative effects on a significant portion of Maryland taxpayers. Recent estimates issued by the Comptroller’s office indicated that 23% of Maryland taxpayers would experience an increase in their state and local taxes due to the new federal code […]

When considering a large charitable gift, individual donors have many options at their disposal. Charitable trusts, donor‑advised funds, and private family foundations are three commonly used charitable giving options. Below is a summary of each option, as well as the advantages and disadvantages of each. Donor advised funds – A donor‑advised fund at a local […]

Eli S. Noff, Esq. CPA It is undisputed that U.S. individuals who own foreign companies were treated unfavorably under the Tax Cuts and Jobs Act of 2017 (TCJA) compared to U.S. corporate shareholders. However, an election that allows individuals to treat themselves as corporations can, in the right circumstances, help alleviate the harsh results. Changes […]

Over the past few years, the IRS has increased its attention on offshore bank accounts, earmarking much of its limited budget, staff, and resources towards initiatives such as the Offshore Voluntary Disclosure Program (OVDP) and Swiss Bank Program, and pushing strict compliance of foreign bank and financial account reporting through enforcement measures such as the […]

Eli Noff, Esq., Partner On April 3, 2018, inUnited States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government’s suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of proof is preponderance of evidence, and (2) proof […]